ML033500135

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NRC Order EA-03-009, Interim Inspection Requirements for Reactor Vessel Heads and Bulleting 2003-02, Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity
ML033500135
Person / Time
Site: Watts Bar 
Issue date: 12/10/2003
From: Pace P
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-03-002, EA-03-009, TAC MB7667, TAC MC0576
Download: ML033500135 (48)


Text

.7 Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 EA-03-009 DEC 1 0 2003 10 CFR 50.54(f)

U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D. C. 20555 Gentlemen:

In the Matter of

)

Docket No.50-390 Tennessee Valley Authority WATTS BAR NUCLEAR PLANT (WBN) UNIT 1 -

NRC ORDER EA-03-009 -

INTERIM INSPECTION REQUIREMENTS FOR REACTOR PRESSURE VESSEL HEADS (TAC NO. MB 7667) AND BULLETIN 2003 LEAKAGE FROM REACTOR PRESSURE VESSEL LOWER HEAD PENETRATIONS AND REACTOR COOLANT PRESSURE BOUNDARY INTEGRITY (TAC NO. MC 0576)

The purpose of this submittal is to provide the inspection results of WBN's Unit 1 reactor pressure vessel (RPV) closure (upper) head and lower head penetration nozzles and head surfaces.

The subject NRC Order, Item IV.C.(3) for plants that fall within the low susceptibility category and the subject Bulletin required a bare metal visual inspection of 100 percent of the RPV head and lower head surfaces (including 360 degrees around each RPV penetration nozzle).

Item IV.E of the Order and Item 2 of the Bulletin required that the Licensee submit a report detailing the inspection results within sixty days after returning the plant to operation.

The RPV closure head and lower head inspections were performed during the WBN Unit 1 Cycle 5 outage which ended October 20, 2003.

Bare metal visual inspections were performed on the heads by Level III Visual Testing (VT) certified personnel using video equipment mounted on remote magnetic crawlers.

The examinations were recorded on video cassettes for archival and off-line review. provides excerpts from Report No. R0922 entitled, "Watts Bar Unit 1, Cycle 5 Reactor Pressure Vessel Closure Head and Lower Head Remote Visual (VT-2) Penetration AIN Pated n cedpap

U.S. Nuclear Regulatory Commission Page 2 DEC 10 2003 Examination" which documents the complete inspection of the closure head and lower head.

Items from the report which are not included in this submittal are copies of the NRC Order and the NRC Bulletin, documentation of Pre-job briefings, inspection procedures, VT certifications, and other supporting documentation.

The original report including the video cassettes of the remote video scan paths, photographs, and resolution verification, is filed as a life of plant document with the Cycle 5 Inservice Inspection Summary Report.

Inspection results of the closure head indicated no observed boron leakage in the examination area of each head penetration.

The penetration annulus areas and the head surface in the area on the penetrations were examined and recorded.

Boron was discovered on Penetration 60, but was concluded to be from a canopy seal weld leak previously identified and repaired during the Cycle 1 refueling outage.

This condition was documented on a problem evaluation report and evaluated under the TVA Corrective Action Program.

The source of boron was from above the penetration, with no evidence seen to indicate the penetration annular area as the source.

The area was cleaned and a liquid penetrant examination was performed on the nozzle surface resulting in no indications. provides a copy of the engineering evaluation.

Details of the closure head visual examination are summarized in Enclosure 1.

Inspection results of the lower head indicated no observed boron leakage in the examination area of each bottom mounted penetration.

The penetration annulus areas and the head surface in the area on the penetrations were examined and recorded.

Light to moderate staining and surface rust was seen around the annular area and on the bare surface.

These areas had trails from above the lower head.

The condition was not associated with boron leakage from the bottom mounted penetrations.

This condition was documented on a problem evaluation report and evaluated under the TVA Corrective Action Program.

Two areas on the head were cleaned.

The surface was observed to be smooth after cleaning and based upon the ease of removal of the substance, it was determined that there is very little rust on the vessel lower head itself. provides a copy of the engineering evaluation.

Details of the lower head visual examination are summarized in Enclosure 1.

U.S. Nuclear Regulatory Commission Page 3 DEC 10 2003 There are no regulatory commitments in this letter.

If you have any questions about this report, please contact me at (423) 365-1824.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 10 th day of December 2003.

Sincerely, P.

Pace Manager, Site Licensing and Industry Affairs Enclosures

1.

Excerpts from Report No. R0922 -

Reactor Pressure Vessel Closure Head and Lower Head Remote Visual (VT-2)

Penetration Examination -

Final Report -

September 2003.

2.

Engineering Evaluation of Reactor Head Examination.

3.

Engineering Evaluation of Reactor Lower Head Surface Rust.

cc (Enclosures):

NRC Resident Inspector Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381 Ms. Margaret H. Chernoff, Project Manager U.S. Nuclear Regulatory Commission MS 08G9 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303

ENCLOSURE 1 WATTS BAR NUCLEAR PLANT UNIT 1 NRC ORDER EA-03-009 AND BULLETIN 2003-02 REACTOR PRESSURE VESSEL CLOSURE HEAD AND LOWER HEAD INSPECTION REPORT NO. R0922 CYCLE 5 EXCERPTS

2~~~~~~~~~~~~~~~~1a' 2os S Watts Bar Unit 1, Cycle 5 - RPV Closure Head REPORT Remote Visual (VT-2) Penetration Examination Final Report Visual Examination Report Summary INTRODUCTION During the Watts Bar Unit 1 (WBN-1), Cycle 5 Refueling Outage, remote visual (VT) examinations were performed on the outside surface of the Reactor Pressure Vessel (RPV) Closure Head and penetrations. The examinations were performed from September 16 to 19, 2003 by Tennessee Valley Authority's (TVA's) Inspection Services Organization (ISO) and R.O.V. Technologies. Any suspect areas were also reviewed by a TVA Metallurgical Engineer.

SUMMARY

The VT examinations were accomplished to address the integrity of the RPV closure head penetrations, including the Control Rod Drive mechanisms (CRD's), Upper Head Injection (UHI) and the Vent line. A total of 83 penetrations were examined, including (78) CRD's, (4) UHI's and (1) Vent line. The examinations were performed to address NRC Order EA^03-009, "Interim Inspection Requirements for Reactor Pressure Vessel Heads At Pressurized Water Reactors". The examination scenario was aimed at determining whether boric acid deposits were emanating from the annulus of the penetrations and identifying the presence of boric acid deposits on the RPV head. The annulus area is defined as the intersection between the RPV head and penetration, inclusive of t/2 inch of adjacent RPV head base material.

The examination was implemented through WBN Work Order # 02-004615-000. The examination fulfills the 1-TRI-0-10, revision 10, augmented examination plans for UlC5. In addition, the examination fulfills NRC Order EA-03-009, Section 3 (a), Bare Metal Visual Examination of 100% of the RPV head penetration nozzles and surrounding head surface.

1

Watts Bar Unit 1, Cycle 5 - RPV Closure Head REPORT Remote Visual (VT-2) Penetration Examination Final Report TECHNICAL DISCUSSION Remote VT Equipment TVA contracted with R.O.V Technologies to provide remote VT equipment to examine the RPV head penetrations. The work was performed in accordance with TVA's ISI Program, 1-TRI-0-10 revisionlO. The remote examinations were performed with R.O.V. magnetic crawlers, outfitted with twin high resolution color cameras, each having adjustable LED lighting arrays. The cameras were located on the front and rear of the remote crawlers.

Access to the examination area was obtained by lifting the insulation shroud approximately 5 inches from the vessel head and installing temporary wooden wedges for stabilization.

The remote crawler was installed on the head surface and guided between the rows of penetrations.

The examinations were recorded on SVHS video cassette's for archival and off-line review.

All penetration annulus areas and the head surface in the area on the penetrations were examined and recorded.

Procedure/Documentation ISO provided Level IlI's certified in Visual examination to review and evaluate all data on-line. All acquired data also had an independent review by certified Level III VT examination personnel. Examination protocol was designed to incorporate the recommendations of the Electric Power Research Institute's (EPRI) Technical Report, entitled "Visual Examination for Leakage of PWR Reactor Head Penetrations on Top of RPV Head", Revision 2 of 1006296, including 2002 Inspection Results. Key technical elements were incorporated into TVA's Nondestructive Examination (NDE) Procedure N-VT-1 7, Revision 3, "Visual Examination for Leakage of PWR Head Penetrations".

The visual examination process utilized enhanced VT-2 methodology with camera resolution established on characters less than or equal to.105" high, representative of VT-3 sensitivity (Ref: Section 4, Figure 1).

2

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Watts Bar Unit 1, Cycle 5-RPV Closure Head REPORT Remote Visual (VT-2) Penetration Examination Final Report Examination Process An examination Scan Plan (Section 3.0) was developed in order to ensure that examinations were performed in a logical sequence, while minimizing radiation exposure and validating positional accuracy. A raster pattern was chosen as the most effective method for performing the examinations and consisted of 22 separate scans.

A total of 323 sequences were performed to examine all penetrations. With the exception of the outer scan rows, each penetration was examined during two scans which consisted of examining four, 90-degree + segments of each penetration to ensure 100% coverage of the annulus area. The outer scan rows, that included the peripheral penetrations, were examined using two scans that covered 180-degrees + of the penetration that resulted in 100% coverage. During the examination of each penetration, the head area adjacent to the penetrations was also visually examined for boron deposits.

Radiation work permit (RWP) number 9070 was used for the inspection work. The data acquisition equipment staging area was located on top of Reactor Coolant Pump Plug No.

2 in a low dose area.

RESULTS Examination results for each penetration are contained in Section 3.0. General information relative to the results of the examinations is provided below:

Canopy Seal Weld Leak Prior to the commencement of examinations, the examination team was apprised of a previous leaking Canopy Seal Welds identified as "G-15, F-2, and G-5" that were detected during Cycle 01 of 1997 and Cycle 02 of 1998. The Canopy Seal welds were located above CRDM No. 62, 60 and 13 respectively. During this exam, penetration number 60 was identified as having boron deposits on the nozzle O.D surface and on the head. This condition was documented on WBN PER # 03-016293-000. The source of the boron was from above the penetration joint, with no evidence seen to indicate the penetration annular area as the source (Ref: Section 4, Figures 2, 3, 4 and 5). The original Canopy Seal Weld leak was repaired on WBN Work Order 97-013542-001. Boron samples were obtained, the area cleaned, and a Liquid Penetrant (PT) exam was performed on the nozzle surface (Ref: WBN Work Order Number 03-016329-000 and ISI Report Number R-0884).

Section 4, figures 6 and 7 contain images of the PT exam and the post exam cleaning condition.

3

Io922 Watts B"! tJnit 1, Cycle 5-RPV Closure Head REPORT Remote Visual (VT-2) Penetration Examination Final Report Insulation Ring Interference Some penetrations had insulation support rings that had moved down the penetration and were resting on the penetration to head area. Although the annulus region was partially restricted, no evidence of boron was noted outside the insulation collar. This condition was noted at locations on the crest of the head where the insulation surface is closest to the RPV head surface (Ref: Example shown in Section 4 Figure 8). Although the insulation rings were present in isolated cases, they did not limit the VT-2 examination for the detection of boron leakage.

RPV Head Coating The RPV Head surface, and exam area were seen to have a coating substance resembling paint. This coating was also seen on the penetration surface adjacent to the head, indicating over run during application. The manufacturer had coated the head at the factory with a coating named Carboline 4674. The condition of the coating varied from tightly adhering, chipped, and to flaking off. (Ref: Section 4, Figures 9, 10, 11 and 12).

Engineering was notified of the condition.

Irrelevant Indications In isolated cases, CRDM's displayed a faint boron appearance "streaking" on the sides of the penetrations, away from the annulus area. These faint areas were either horizontal or vertical with origination from above. The horizontal areas appeared to have been*

deposited by high velocity air in the plenum, during operation. The condition was not associated with boron originating from the annulus. An example of this condition is d6picted in Figures 13 and 14 (CRDM No. 64).

Foreign Material Foreign material was noted on the head surface in two areas at the penetration annular junction. In both locations the material was retrieved by R.O.V. using remote gripping devices. After removal, the newly uncovered area was examined and recorded. Table 1 lists the types of foreign material that were seen during the examinations.

TABLE 1 CRDM Figure Identification Number Description 63 15 & 16 Partial hose clamp strap 67 17 & 18 Drill bit tip 4

Watts Bar Unit 1, Cycle 5-RPV Closure Head REPORT Remote Visual (VT-2) Penetration Examination Final Report In general, the head surface was relatively free from debris. The heaviest concentrations were seen on the uphill side of periphery penetrations and were easily removed by blowing air onto the area. The materials did not preclude an effective examination of the annulus regions of the penetrations.

CONCLUSION There were no observed indications of boron leakage in the exam area of each-penetration. After cleaning at penetration 60, there was no evidence of boron on the RPV Head surface.

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WBN U1C5 RPV UPPER HEAD VISUAL EXAMINATION SECTION 4 PHOTOS Figure 1: Visual Illumination Card used to resolve VT-3 characters

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Figure 7: Penetration 60, cleaning after PT exam.

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TENNESSEE VALLEY RECORD OF LIQUID REPORT NUMBER AUTHORITY PENETRANT EXAM R-Ru88 PROJECT: WjJi3 UNIT:j CYCLE:

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BLACK LIGHT MNIETER S/IN:

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'Plitts Bar Unit 1, Cycle 5 - P.P' Lower Head Remote Visual Penetration Examination Final Report 9f o

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Visual Examination Report Summary INTRODUCTION During the Watts Bar Unit 1 (WBN-1), Cycle 5 Refueling Outage, remote visual (VT) examinations were performed on the outside surface of the Reactor Pressure Vessel (RPV) Lower Head bottom mounted instrument (BMI) penetrations. TVA Inspection Services Organization (ISO) established a procedure to define the actions required to perform effective VT-2 examinations to detect reactor coolant pressure boundary (RCPB) leakage from the reactor vessel lower head penetrations and the RCPB. The examinations were performed on September 10 and 11, 2003 by Tennessee Valley Authority's (TVA's)

Inspection Services Organization (ISO) and R.O.V Technologies. Any suspect areas were also reviewed by a TVA Metallurgical Engineer.

SUMMARY

The examination was implemented through WBN Work Order # 03-002925-000. The examinations were performed in accordance with TVA/ISO NDE procedure N-VT-1 7, revision 3. The purpose of the VT examinations was to identify any leakage from the instrument penetration annulus area and any degradation of the lower head from RCPB leakage. The annulus area is defined as the intersection between the RPV head and penetration, inclusive of 1/2 inch of adjacent RPV head base material. The examination included 100% of the RPV head surface and 360 degrees of the annulus. A total of 58 BMI penetrations and the lower head surface were examined. Personnel performing the examinations were certified as VTI LIII. System resolutions checks were required at the initiation and completion of the exam. Any suspected boron leakage areas were to be identified to Materials Engineering for resolution.

1

Watts Bar Unit 1, Cycle 5 - RPV Lower Head Remote Visual Penetration Examination Final Report TECHNICAL DISCUSSION Remote VT Equipment TVA contracted with R.O.V. Technologies to provide remote VT equipment to examine the RPV head penetrations. The work was performed as part of the WBN/ISI program, augmented exam section, of 1 -TRI-0-1 0, revision 10. The remote examinations were performed with a R.O.V. tracked crawler, outfitted with high a resolution color camera having an adjustable LED lighting array, tilt and zoom capabilities. In addition, a stationary camera was used to assist in positional verification.

The data acquisition and crawler control station were located on a platform above the seal table with the associated cabling routed through a panel in the seal table to the RPV lower head. The camera mounted crawler and stationary camera were placed under the head on the insulation surface. Access to the examination area was provided by removing the peripheral insulation panels located below the vessel head. A ladder was placed at one of these openings. The task required confined space monitoring and Radcon support for the initial and subsequent entries into the keyway.

The examinations were recorded on SVHS video cassette's for archival and off-line review. All penetration annulus areas and the head surface in the area on the penetrations were examined and digitally recorded.

Procedure/Documentation The exam was performed in accordance with TVA/ISO NDE procedure N-VT-1 7, revision 3.

ISO provided two Level IlIl examiners certified in Visual examination to review and evaluate all data on-line.

The visual examination process utilized VT-2 methodology with camera resolution established on characters less than or equal to.105" high, representative of VT-3 sensitivity. (Ref: Section 4, Figure 1) 2

Watts Bar Unit 1, Cycle 5-RPV Lower Head IC C

Remote Visual Penetration Examination Final Report 97,

$7 Examination Process An examination Scan Plan (Section 3.0) was developed in order to ensure that examinations were performed in a logical sequence, while minimizing radiation exposure and validating positional accuracy.

A total of 15 scan sequences were performed to examine all penetrations. During the examination of each penetration, the head area adjacent to the penetration was also visually examined for boron deposits.

Radiation work permit number 8180 was used for the inspection work.

RESULTS Bare Head Surface Condition On nearly all exams, light to moderate staining and surface rust was seen around the annular area and on the bare head surface. These areas had trails from above the bottom head. The condition was not associated with boron leakage from the BMI penetrations.

Ref: Section 4: Figures 2, 3, 5, 8, and 9.

There was also an area that exhibited apparent tape residue adjacent to the BMI penetration. Ref: Section 4: Figure 4.

Site Engineering will evaluate the overall condition of the RPV lower head in accordance with the corrosion control program (Ref: WBN PER # 03-016599-000)

Observations A spun steel material was observed at the majority of the intersections formed by the insulation to BMI tubing. This material was also seen lying loose on the insulation surface.

Although it did not present an obstruction, the material itself was a concern and did become entangled in the crawler tracks on three occasions. The material was removed by remote manipulation of the crawler. It is suggested that an evaluation be made to remove this material to prevent possible damage to the remote device. This action would present an opportunity to lessen dose (if manual retrieval was required), lessen outage schedule impact resulting from repair delays and could be a cost savings if replacement equipment was purchased.

Ref: Section 4: Figure 7 3

Watts Bar Unit 1, Cycle 5 - RPV Lower Head Remote Visual Penetration Examination Final Report

'S o- /a/

Another observation was the "loose parts monitoring" instrument wiring seen at penetrations 24 and 38. The wiring at penetration 24 was loosely bundled and was an obstacle for the crawler. The wiring at penetration 38 was installed tightly against the surfaces and was not an obstacle. It is suggested that an evaluation be made to readjust the material at penetration 24 to prevent a possible obstruction for future exams. WBN Work order # 03-016028-000 was written to address this condition.

Ref: Section 4: Figure 6 CONCLUSION The VT examinations of all penetrations were found to have no evidence of boron leakage. All penetrations were accessible and all penetrations were examined.

Examination results for each penetration are contained in Section 3.0.

4

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WBN U1C5 RPV LOWER HEAD VISUAL EXAMINATION SECTION 4 PHOTOS FIG.l: VISUAL ILLUMINATION CARD USED TO RESOLVE VT-3 CHARACTERS FIG.2: PENETRATION 28 (VIEW 1) TYPICAL AS FOUND CONDITION

WBN U1C5 RPV LOWER HEAD VISUAL EXAMINATION SECTION 4 PHOTOS FIG. 3: PENETRATION 28 (VIEW 2) TYPICALAS FOUND CONDITION FIG.4-PENETRATION 07: TAPE RESIDUE

WBN U1C5 RPV LOWER HEAD VISUAL EXAMINATION SECTION 4 PHOTOS FIG. 5: PENETRATION 58. CLOSE UPVIEW OF ANNULAR AREA VLI FIG. 6: INSTRUMENTATION WIRINGOBSTICLE IN SCAN PATH AT PENETRATION 24

WBN U1C5 RPV LOWER HEAD VISUAL EXAMINATION SECTION 4 PHOTOS 111 H at.:.

FIG.7: SPUN STEEL MATERIAL AT INSULATION/TUBING JOINTS FIG.8: GENERAL VIEW OF BARE HEAD CONDITION FROM PEDESTAL CAMERA

WBN U1C5 RPV LOWER HEAD VISUAL EXAMINATION SECTION 4 PHOTOS FIG.9: GENERAL VIEW OF BARE HEAD CONDITION FROM PEDESTAL CAMERA

ENCLOSURE 2 WATTS BAR NUCLEAR PLANT UNIT 1 NRC ORDER EA-03-009 AND BULLETIN 2003-02 REACTOR PRESSURE VESSEL CLOSURE HEAD AND LOWER HEAD INSPECTION ENGINEERING EVALUATION OF CLOSURE HEAD

ENCLOSURE 2 WATTS BAR NUCLEAR PLANT UNIT 1 NRC ORDER EA-03-009 AND BULLETIN 2003-02 REACTOR PRESSURE VESSEL CLOSURE HEAD AND LOWER HEAD INSPECTION ENGINEERING EVALUATION OF CLOSURE HEAD PER~ 03-01G2q3-00 Reactor Head Examination Reactor Head Inspection has been completed with one CRDM penetration requiring further evaluation.

There was evidence of boron residue on CRDM Penetration #60 below the Insulation and on the peripheral CRDM area. PER 03-016293-000 was Initiated to document this condition.

WO 03-016329-000 was Issued to clean the penetration and the adjacent head area and the penetration was examined by liquid penetrant (N-PT-9) examination on 9/19/03. The head was cleaned and the examination Identified no relevant or non-relevant indications. It has been noted that a canopy seal weld leak on this CRDM was Identified during RF01 and was repaired under WO 97-013542-001.

The only other issue associated with the Head Inspection was the identification of a small amount of debris. This debris was removed on 9-1 9-03.

All Reactor Head Inspection work Is complete with only the documentation requiring fInal review and processing. A formal detailed report of the Inspection and findings Is In process and Is forecast to be completed 10/03/03. These findings and the report will be documented In PER 03-016293-000.

At this time Design Engineering is not aware of and does not have any additional Inspections or work scope required to be performed on the Reactor Head during U1 C5.

Prepared by-.

Date: 920/03 Reviewed by:

De Date: 9120!03 E2-1

ENCLOSURE 3 WATTS BAR NUCLEAR PLANT UNIT 1 NRC ORDER EA-03-009 AND BULLETIN 2003-02 REACTOR PRESSURE VESSEL CLOSURE READ AND LOWER HEAD INSPECTION ENGINEERING EVALUATION OF LOWER HEAD SURFACE

ENCLOSURE 3 WATTS BAR NUCLEAR PLANT UNIT 1 NRC ORDER EA-03-009 AND BULLETIN 2003-02 REACTOR PRESSURE VESSEL CLOSURE HEAD AND LOWER HEAD INSPECTION ENGINEERING EVALUATION OF LOWER HEAD SURFACE PER 03-016599-000 Inspection of Surface Rust on the Unit 1 Reactor Vessel Lower Head The subject PER documents the presence of rust on the surface of the reactor vessel lower head. This rust was photographed during the remote inspection that was performed on the bottom mounted penetrations. This rust was believed to be tightly adhering, light surface rust based on the photos and video taken during the inspection. A subsequent inspection was performed on 1011212003 by Modifications and Design Engineering personnel to determine the extent of the rust on the surface of the lower head.

Two areas, approximately 6" X 6", were selected for cleaning and review. One of the two areas selected contained rust colorations consistent with the majority of the lower head, while the other area was selected because the rust colorations looked heavier in that location. The inspection involved wiping the surface with a damp cloth, removing the substance with a lightly wetted pad of Scotchbrite, and wiping the area a final time with a damp cloth. The two areas cleaned up with minimal effort, and were wiped down to expose the surface of the head. The surface of the lower head was observed to be smooth after cleaning the two areas. The substance was mostly removed during the initial wipe down with the damp cloth. The substance on the lower head is believed to be a combination of light rust and what remains of an initial protective coating. Based upon the ease of removal of the substance, it is determined that there is very little rust on the vessel lower head itself. The substance left a brownish-black, thick residue on the cloth after wiping, which led to the conclusion that there was some of the initial protective coating present. Both areas contained only light rust, and these areas are considered to be representative of the condition on the lower head.

This observation is consistent with the determination made during the ROV inspection at the start of the outage. Therefore, no further corrective action will be required.

Cleaning and inspection performed by Tommy Baird, Modifications.

t.9 fO/I5/ZOoF Inspection and Evaluation performed by Robert Kirkpatrick, Mechanical Design.

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